Henry Joseph Stevens v. United States
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Whether the ACCA's demand for certainty constrains a federal court's interpretation of conflicting state-law decisions
QUESTIONS PRESENTED 1. When evaluating whether a state-law offense satisfies the Armed Career Criminal Act’s definition of a “violent felony,” 18 U.S.C. § 924(e)(2)(B), federal courts often have to interpret and apply state court decisions. Where state-law sources conflict with one another, does the ACCA’s “demand for certainty” constrain a federal court’s interpretation of state criminal law? 2. Mr. Stevens was previously convicted of robbery under Texas Penal Code § 29.03, a statute that incorporates the definition of robbery from § 29.02 of the Texas Penal Code, which allows conviction when a thief recklessly causes someone to suffer injury or causes someone to fear imminent bodily injury. Does Texas aggravated robbery have “as an element the use, attempted use, or threatened use of physical force against the person of another,” 18 U.S.C. § 924(e)(2)(B)@)? i